Japan Submits Draft Pillar Two Law to Parliament

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On February 3 and 6, 2023, the Ministry of Finance published the “Bill for Partial Revision of the Income Tax Act” This includes the proposed implementation of the Pillar Two GloBE rules from April 2024.

Blended CFC Calculator

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For fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027, the OECD Administrative Guidance includes a simplified formula to allocate CFC taxes in blended CFC regime. Use our simple calculator.

GILTI & Blended CFC Regimes

QDMTT Design Features

Article 2.10 of the Administrative Guidance provides more information on the treatment of the US Global Intangible Low-Taxed Income (GILTI) regime.